Russian companies, representative offices and branches of foreign companies must develop and implement internal measures aimed at preventing bribery.
These include, amongst others, appointing compliance officers, adopting internal codes of ethics and policies for all employees, cooperating with law enforcement authorities.
To help companies implement effective anti-corruption measures, the Ministry of Labour and Social Protection has developed new recommendations on combating corruption in organisations.
These recommendations include adopting measures aimed at minimising corruption risks for companies and, in particular, those related to:
- developing anti-corruption policies and standards;
- settling conflicts of interest;
- interacting with employees;
- building an effective system for obtaining information on corruption offences; and
- interacting with law enforcement agencies.
To date, no sanctions are provided for failure to take anti-corruption compliance measures. However, the General Prosecutor’s Office may file a claim to demand the implementation of anti-corruption measures. Moreover, in the event of checks by the authorities (police, public prosecutor, etc.), an order to remedy the failure can be issued against the delinquent company. In turn, failure to implement this kind of order carries administrative sanctions, namely fines and/or the disqualification of the company’s general director from holding office for up to three years.